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Republic of the Philippines July 29, 2011 to the corporation's stockholders, hence, their plea for
SUPREME COURT injunction.
Manila
The case was raffled to Branch 276, which is not a Special Commercial
EN BANC Court. After filing their respective answers to the complaint,
respondents filed a motion to dismiss on the ground of lack of
G.R. No. 202664, November 20, 2015 jurisdiction over the subject matter, pointing out that the case involves
an intra-corporate dispute and should, thus, be heard by the
MANUEL LUIS C. GONZALES AND FRANCIS MARTIN D. designated Special Commercial Court of Muntinlupa City.
GONZALES, Petitioners,
vs. The RTC Ruling
GJH LAND, INC. (FORMERLY KNOWN AS S.J. LAND, INC.),
CHANG HWAN JANG A.K.A. STEVE JANG, SANG RAK KIM, In an Order14 dated April 17, 2012, Branch 276 granted the motion to
MARIECHU N. YAP, AND ATTY. ROBERTO P. MALLARI II, dismiss filed by respondents. It found that the case involves an intra-
Respondent. corporate dispute that is within the original and exclusive jurisdiction
of the RTCs designated as Special Commercial Courts. It pointed out
PERLAS-BERNABE, J.: that the RTC of Muntinlupa City, Branch 256 (Branch 256) was
specifically designated by the Court as the Special Commercial Court,
FACTS hence, Branch 276 had no jurisdiction over the case and cannot
lawfully exercise jurisdiction on the matter, including the issuance of a
On August 4, 2011, petitioners Manuel Luis C. Gonzales and Francis Writ of Preliminary Injunction.
Martin D. Gonzales (petitioners) filed a Complaint for "Injunction with
prayer for Issuance of Status Quo Order, Three (3) and Twenty (20)- Petitioners Contend
Day Temporary Restraining Orders, and Writ of Preliminary
Injunction with Damages" against respondents GJH Land, Inc. Dissatisfied, petitioners filed a motion for reconsideration, arguing that
(formerly known as S.J. Land, Inc.), Chang Hwan Jang, Sang Rak Kim, they filed the case with the Office of the Clerk of Court of the RTC of
Mariechu N. Yap, and Atty. Roberto P. Mallari II6 (respondents) before Muntinlupa City which assigned the same to Branch 276 by raffle. As
the RTC of Muntinlupa City seeking to enjoin the sale of S.J. Land, the raffle was beyond their control, they should not be made to suffer
Inc.'s shares which they purportedly bought from S.J. Global, Inc. the consequences of the wrong assignment of the case, especially after
paying the filing fees in the amount of P235,825.00 that would be for
On February 1, 2010. Essentially, petitioners alleged that the naught if the dismissal is upheld.
subscriptions for the said shares were already paid by them in full in
the books of S.J. Land, Inc., but were nonetheless offered for sale on

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ISSUE: Whether or not a commercial case should be dismissed if Therefore, one must be disabused of the notion that the transfer of
erroneously raffled to a regular civil court instead of a special jurisdiction was made only in favor of particular RTC branches, and
commercial court. not the RTCs in general.

HELD: NO. Here, petitioners filed a commercial case, i.e., an intra-corporate

dispute, with the Office of the Clerk of Court in the RTC of
As a basic premise, let it be emphasized that a court's acquisition of Muntinlupa City, which is the official station of the designated Special
jurisdiction over a particular case's subject matter is different from Commercial Court, in accordance with A.M. No. 03-03-03-SC. It is,
incidents pertaining to the exercise of its jurisdiction. Jurisdiction over therefore, from the time of such filing that the RTC of Muntinlupa City
the subject matter of a case is conferred by law, whereas a court's acquired jurisdiction over the subject matter or the nature of the action.
exercise of jurisdiction, unless provided by the law itself, is governed Unfortunately, the commercial case was wrongly raffled to a regular
by the Rules of Court or by the orders issued from time to time by the branch, e.g., Branch 276, instead of being assigned to the sole Special
Court. In Lozada v. Bracewell, it was recently held that the matter of Commercial Court in the RTC of Muntinlupa City, which is Branch
whether the RTC resolves an issue in the exercise of its general 256. This error may have been caused by a reliance on the complaint's
jurisdiction or of its limited jurisdiction as a special court is only a caption, i.e., "Civil Case for Injunction with prayer for Status Quo
matter of procedure and has nothing to do with the question of Order, TRO and Damages," which, however, contradicts and more
jurisdiction. importantly, cannot prevail over its actual allegations that clearly make
out an intra-corporate dispute.
Pertinent to this case is RA 8799 which took effect on August 8, 2000.
By virtue of said law, jurisdiction over cases enumerated in Section 5 of Going back to the case at bar, the Court nonetheless deems that the
Presidential Decree No. 902-A was transferred from the Securities and erroneous raffling to a regular branch instead of to a Special
Exchange Commission (SEC) to the RTCs, being courts of general Commercial Court is only a matter of procedure - that is, an incident
jurisdiction. related to the exercise of jurisdiction - and, thus, should not negate the
jurisdiction which the RTC of Muntinlupa City had already acquired.
To clarify, the word "or" in Item 5.2, Section 5 of RA 8799 was In such a scenario, the proper course of action was not for the
intentionally used by the legislature to particularize the fact that the commercial case to be dismissed; instead, Branch 276 should have first
phrase "the Courts of general jurisdiction" is equivalent to the phrase referred the case to the Executive Judge for re-docketing as a
"the appropriate Regional Trial Court." In other words, the jurisdiction commercial case; thereafter, the Executive Judge should then assign
of the SEC over the cases enumerated under Section 5 of PD 902-A was said case to the only designated Special Commercial Court in the
transferred to the courts of general jurisdiction, that is to say (or, station, i.e., Branch 256.
otherwise known as), the proper Regional Trial Courts.
Note that the procedure would be different where the RTC acquiring
jurisdiction over the case has multiple special commercial court
branches; in such a scenario, the Executive Judge, after re-docketing
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the same as a commercial case, should proceed to order its re-raffling To restate, the designation of Special Commercial Courts was merely
among the said special branches. intended as a procedural tool to expedite the resolution of commercial
cases in line with the court's exercise of jurisdiction. This designation
Meanwhile, if the RTC acquiring jurisdiction has no branch designated was not made by statute but only by an internal Supreme Court rule
as a Special Commercial Court, then it should refer the case to the under its authority to promulgate rules governing matters of
nearest RTC with a designated Special Commercial Court branch procedure and its constitutional mandate to supervise the
within the judicial region. Upon referral, the RTC to which the case administration of all courts and the personnel thereof. Certainly, an
was referred to should re-docket the case as a commercial case, and internal rule promulgated by the Court cannot go beyond the
then: (a) if the said RTC has only one branch designated as a Special commanding statute. But as a more fundamental reason, the
Commercial Court, assign the case to the sole special branch; or (b) if designation of Special Commercial Courts is, to stress, merely an
the said RTC has multiple branches designated as Special Commercial incident related to the court's exercise of jurisdiction, which, as first
Courts, raffle off the case among those special branches. discussed, is distinct from the concept of jurisdiction over the subject
matter. The RTC's general jurisdiction over ordinary civil cases is
In all the above-mentioned scenarios, any difference regarding the therefore not abdicated by an internal rule streamlining court
applicable docket fees should be duly accounted for. On the other procedure.
hand, all docket fees already paid shall be duly credited, and any
excess, refunded. In fine, Branch 276's dismissal of Civil Case No. 11-077 is set aside and
the transfer of said case to Branch 256, the designated Special
For further guidance, the Court finds it apt to point out that the same Commercial Court of the same RTC of Muntinlupa City, under the
principles apply to the inverse situation of ordinary civil cases filed parameters above-explained, is hereby ordered.
before the proper RTCs but wrongly raffled to its branches designated
as Special Commercial Courts. In such a scenario, the ordinary civil WHEREFORE, the petition is GRANTED. The Orders dated April 17,
case should then be referred to the Executive Judge for re-docketing as 2012 and July 9, 2012 of the Regional Trial Court (RTC) of Muntinlupa
an ordinary civil case; thereafter, the Executive Judge should then City, Branch 276 in Civil Case No. 11-077 are hereby REVERSED and
order the raffling of the case to all branches of the same RTC, subject to SET ASIDE. Civil Case No. 11-077 is REFERRED to the Executive
limitations under existing internal rules, and the payment of the Judge of the RTC of Muntinlupa City for re-docketing as a commercial
correct docket fees in case of any difference. Unlike the limited case. Thereafter, the Executive Judge shall ASSIGN said case to Branch
assignment/raffling of a commercial case only to branches designated 256, the sole designated Special Commercial Court in the RTC of
as Special Commercial Courts in the scenarios stated above, the re- Muntinlupa City, which is ORDERED to resolve the case with
raffling of an ordinary civil case in this instance to all courts is reasonable dispatch. In this regard, the Clerk of Court of said RTC
permissible due to the fact that a particular branch which has been shall DETERMINE the appropriate amount of docket fees and, in so
designated as a Special Commercial Court does not shed the RTC's doing, ORDER the payment of any difference or, on the other hand,
general jurisdiction over ordinary civil cases under the imprimatur of refund any excess.
statutory law, i.e., Batas Pambansa Bilang (BP) 129.
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Furthermore, the Court hereby RESOLVES that henceforth, the Commercial Court, then the case shall be referred to the
following guidelines shall be observed: Executive Judge for re-docketing as an ordinary civil case.
Thereafter, it shall be raffled off to all courts of the same
1. If a commercial case filed before the proper RTC is RTC (including its designated special branches which, by
wrongly raffled to its regular branch, the proper courses statute, are equally capable of exercising general
of action are as follows: jurisdiction same as regular branches), as provided for
under existing rules.
1.1 If the RTC has only one branch designated as a
Special Commercial Court, then the case shall be 3. All transfer/raffle of cases is subject to the payment of
referred to the Executive Judge for re-docketing as a the appropriate docket fees in case of any difference. On
commercial case, and thereafter, assigned to the sole the other hand, all docket fees already paid shall be duly
special branch; credited, and any excess, refunded.

1.2 If the RTC has multiple branches designated as 4. Finally, to avert any future confusion, the Court
Special Commercial Courts, then the case shall be requires that all initiatory pleadings state the action's
referred to the Executive Judge for re-docketing as a nature both in its caption and body. Otherwise, the
commercial case, and thereafter, raffled off among initiatory pleading may, upon motion or by order of the
those special branches; and court motu proprio, be dismissed without prejudice to its
re-filing after due rectification. This last procedural rule is
1.3 If the RTC has no internal branch designated as a prospective in application.
Special Commercial Court, then the case shall be
referred to the nearest RTC with a designated 5. All existing rules inconsistent with the foregoing are
Special Commercial Court branch within the judicial deemed superseded.
region. Upon referral, the RTC to which the case
was referred to should re- docket the case as a SO ORDERED.
commercial case, and then: (a) if the said RTC has
only one branch designated as a Special Commercial
Court, assign the case to the sole special branch; or
(b) if the said RTC has multiple branches designated
as Special Commercial Courts, raffle off the case
among those special branches.

2. If an ordinary civil case filed before the proper RTC is

wrongly raffled to its branch designated as a Special
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